No Surprises Act 2026: Mastering the New Federal IDR Final Rule and Compliance Requirements

This session is designed to help healthcare professionals understand the latest federal updates, compliance expectations, and practical implications of the evolving No Surprises Act framework, particularly regarding the Independent Dispute Resolution (IDR) process and payer registry requirements.

The new rule, finalized on May 28, 2026, introduces several key reforms to the federal IDR process under the No Surprises Act. Specifically, health plans and issuers must include arbitration registration numbers in initial payment notices and use standardized billing codes in remittance advice. Mandatory registration in the Federal IDR Portal is now required, and failure to register constitutes a compliance violation.

The open negotiation process has been streamlined, requiring parties to submit additional eligibility information upfront while prohibiting duplicative submissions through proprietary portals. A new 50-line-item cap applies to batched disputes, while permissible batching categories have been expanded and the cooling-off period has been reduced from 90 calendar days to 30 business days.

In addition, certified IDR entities are subject to enhanced oversight, monitoring, and potential decertification for noncompliance. Finally, the per-party administrative fee has been reduced from $115 to $15, significantly lowering the financial barrier to initiating legitimate disputes.

• Understand the origins of the No Surprises Act: Explain the balance billing problem that prompted congressional action and how the NSA shifted financial responsibility from patients to providers and payers.
• Describe how the federal IDR process was designed to function: Identify the baseball-style arbitration model, its intended purpose, and how high dispute volumes and litigation contributed to system challenges following its 2022 launch.
• Identify the key disclosure and communication requirements under the new final rule: Explain the new obligations to include arbitration registration numbers in initial payment notices and to use standardized CARCs and RARCs in remittance advice.
• Analyze the overhauled open negotiation and eligibility review process: Describe the updated initiation procedures, response deadlines, the prohibition of proprietary portal submissions, and the 5-business-day eligibility determination window.
• Apply the revised batching and bundling rules to real-world disputes: Explain the new 50-line-item cap, expanded batching categories, and shortened cooling-off period, and assess how these changes affect dispute strategies for both providers and payers.
• Evaluate the significance of mandatory Federal IDR Portal registration: Explain the registration requirements, compliance timelines, consequences of noncompliance, and how registration supports a more transparent and auditable dispute process.
• Assess the impact of the 87% administrative fee reduction and enhanced arbitrator accountability: Analyze how the fee reduction from $115 to $15 per party affects incentives for high-volume filers, and explain the new corrective action and decertification framework for certified IDR entities.
• Identify the legal issues that remain unresolved under the final rule: Describe the pending en banc Fifth Circuit litigation regarding QPA calculation methodology, the absence of restored QPA-primacy standards for arbitrators, and the implications of the ruling that providers lack a private right of action to enforce IDR awards.

• Background and Purpose of the No Surprises Act 
• Evolution of the Federal IDR Process:
• Intended role of independent dispute resolution 
• Key implementation challenges
• Overview of the 2026 Final Rule:
• Regulatory objectives 
• New Requirements for Initial Payment Notices:
• Arbitration registration number requirements 
• Notice content expectations 
• Compliance considerations 
• Major policy changes 
• Compliance timelines 
• Standardized Remittance Advice Requirements:
• Use of CARCs and RARCs 
• Communication consistency standards 
• Operational implications for payers
• Mandatory Federal IDR Portal Registration:
• Registration process and deadlines 
• Required participant information 
• Consequences of noncompliance
• Enhanced Eligibility Review Procedures:
• New submission requirements 
• Eligibility screening standards 
• Review timelines and outcomes
• Changes to the Open Negotiation Process:
• Updated initiation procedures 
• Documentation expectations
• Restrictions on Proprietary Portal Submissions:
• Prohibited practices 
• Federal portal usage requirements 
• Compliance best practices
• Revised Batching and Bundling Standards:
• New 50-line-item cap 
• Expanded batching categories 
• Operational impact on dispute management
• Reduced Cooling-Off Period Requirements:
• Transition from 90 calendar days to 30 business days 
• Effects on filing strategies 
• Timeline management considerations
• Administrative Fee Reduction:
• Reduction from $115 to $15 per party 
• Impact on dispute accessibility 
• Potential effects on filing volume 
• Increased Oversight of Certified IDR Entities:
• Monitoring and performance expectations 
• Corrective action procedures 
• Decertification risks
• Legal and Regulatory Uncertainties:
• Fifth Circuit litigation involving QPA methodology 
• Ongoing policy debates 
• Areas requiring future guidance
• Compliance Strategies and Operational Readiness:
• Preparing internal teams for new requirements 
• Updating policies and workflows 
• Reducing compliance and reimbursement risks
• Interactive Q&A session after the webinar and receive direct answers from our expert speaker

• Hospital and Health System In-House Counsel 
• Directly responsible for No Surprises Act compliance and IDR dispute strategy on the provider side. 
• Physician Group Administrators and Practice Managers 
• Manage billing operations and are directly affected by the new initiation, batching, and eligibility requirements. 
• Health Plan and Insurer Legal and Compliance Teams 
• Responsible for implementing the new disclosure, registration, and billing code requirements on the payer side. 
• Third-Party Administrators (TPAs) 
• Administer employer-sponsored health plans and must comply with portal registration and remittance advice requirements. 
• Revenue Cycle Management (RCM) Professionals 
• Handle claims, remittance processing, and dispute initiation on behalf of providers, making them key operational stakeholders. 
• Healthcare Regulatory and Transactional Attorneys 
• Advise provider and payer clients on compliance with the evolving federal IDR framework. 
• Self-Funded Employer Plan Sponsors and HR Executives 
• Oversee plan administration under ERISA and must understand their responsibilities related to the Federal IDR process. 
• Certified IDR Entity Representatives 
• Subject to the new accountability, monitoring, corrective action, and decertification requirements. 
• Anesthesiology Group Leaders and Administrators 
• Frequently involved in out-of-network reimbursement disputes and affected by specialty-specific batching provisions. 
• Radiology Group Leaders and Administrators 
• Need to understand how the revised dispute resolution process impacts reimbursement and compliance. 
• Pathology and Laboratory Practice Leaders 
• Will benefit from guidance on batching rules, dispute eligibility, and operational compliance. 
• Air Ambulance Operators and Legal Counsel 
• NSA protections specifically apply to air ambulance services, making these regulatory updates highly relevant. 
• Healthcare Consultants and Managed Care Advisors 
• Advise healthcare organizations on contracting, reimbursement strategy, and dispute resolution processes. 
• Government Affairs and Policy Professionals 
• Monitor healthcare regulatory developments, litigation, and federal policy changes affecting the industry. 
• Medical Billing and Coding Managers 
• Responsible for accurate claims submission, remittance review, and compliance with standardized coding requirements. 
• Healthcare Compliance Officers 
• Ensure organizational adherence to federal regulations, reporting obligations, and internal compliance programs. 
• Managed Care Contracting Professionals 
• Negotiate payer-provider agreements and evaluate how IDR changes affect reimbursement strategies. 
• Healthcare Financial Executives (CFOs, Revenue Integrity Leaders, and Finance Directors) 
• Oversee financial performance, reimbursement trends, dispute costs, and regulatory risk management associated with the No Surprises Act.

Megan McKisson, Esq. is a healthcare litigator at Sheppard Mullin Richter & Hampton LLP with extensive experience representing leading health plans in high-profile federal litigation and statutory arbitration matters. Her practice focuses on complex healthcare disputes, regulatory compliance, and reimbursement issues, with particular emphasis on matters arising under the No Surprises Act (NSA).

Megan has handled numerous first-impression cases involving the NSA, providing clients with strategic guidance on the law’s evolving requirements and its impact on provider-payer relationships. She regularly advises health plans and other healthcare stakeholders on compliance obligations, dispute resolution strategies, arbitration proceedings, and litigation risks related to out-of-network reimbursement disputes.

As the regulatory landscape continues to evolve, Megan helps organizations navigate emerging federal requirements, interpret new regulations, and develop practical approaches to managing compliance challenges. Her experience spans both litigation and arbitration, giving her a comprehensive understanding of the legal and operational issues that affect healthcare payers and providers.

Drawing on her hands-on experience with some of the most significant NSA-related disputes and regulatory developments, Megan brings valuable insights into the latest changes affecting the federal IDR process, payer obligations, and healthcare reimbursement practices.